HomeMy WebLinkAbout99-03028yi)
e
it
IN THE COURT OF COMMON
OF CUMBERLAND COUNTY
STATE OF +'?? PENNA.
Christa Zerbe LeMasters,
Plaintiff,
.................................... ....................... ......... ... ?I
Versus
Garrison Winfield LeMasters,
Defendant,
PLEAS
No . ...3028 ........... .................. 1999
DECREE IN
DIVORCE
AND NOW,... 1.(n...... , AA.?°60, it is ordered and
Chris Zerbe
..... a ..... LeMasters plaintiff,
decreed that .
and Garrison Winfield LeMasters defendant,
............................................
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
None. The Marital Settlement Agreement executed by the parties on November
22, 1999, is incorporated herein, but shall not merbe into. said Decree„
..........................................
y
i
By The qoustG
!
Attes VV Ci? O ?7; C J:
Prothonotary
v
a: : 'WI W. u: ttl> W. .?. .tl. ttl; .?. ,c• .tl. .tl. .c• e. .IV 10. 1 ... a. t; .e .?%
._
S,IWPDOCS\DOMESTIC\h, 'oAUema,sters.msa.wpd
August 25, 1999
I V
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this day of ??- u7\ t? C. - 1999, by and
between CHRISTALERBE LEMASTERS of Gaithersburg, Maryland, (hereinafter "WIFE")
and GARRISON WINFIELD LEMASTERS, (hereinafter "HUSBAND");
WITNESSETH:
WHEREAS, the parties hereto were married on January 8, 1994, in Cumberland
County, Pennsylvania; and
WHEREAS, a divorce action was filed by WIFE on or about May 19, 1999, in the
Cumberland County Court of Common Pleas at 99-3028 CIVIL ACTION -LAW; and
WHEREAS, difficulties have arisen between the parties and it is therefore their
intention to live separate and apart for the rest of their lives and the parties are desirous of
settling completely the economic and other rights and obligations between each other,
including, but not limited to: the equitable distribution of the marital property; past, present
and future support; alimony, alimony pendente lite; and, in general, any and all other claims
and possible claims by one against the other or against their respective estates; and
NOW THEREFORE, in consideration of the covenants and promises hereinafter to be
kept and performed by each party and intending to be legally bound hereby, the parties do
hereby agree as follows:
Page 1 of 10
S:\W PDOCS\DOMESTIC\IASAUomssters.msa.wpd
August 25, 1999
1. ADVICE OF COUNSEL.
The provisions of this agreement and their legal effect have been fully explained
to the parties by their respective counsel. WIFE is represented by Debra Denison Cantor,
Esquire. HUSBAND is unrepresented.
The parties further declare that each is executing the Agreement freely and
voluntarily having either obtained sufficient knowledge and disclosure of their respective legal
rights and obligations or, if counsel has not been consulted, expressly waiving the right to
obtain such knowledge. The parties each acknowledge that this Agreement is fair and
equitable and is not the result of any fraud, coercion, duress, undue influence or collusion.
2. DIVORCE ACTION.
The parties acknowledge that their marriage is irretrievably broken and that they
shall secure a mutual consent no fault divorce pursuant to § 3301(c) of the Divorce Code. The
parties agree to execute Affidavits of Consent for divorce and Waivers of Notice of Intention to
Request Entry of a Divorce Decree concurrently with the execution of this Agreement.
This Agreement shall remain in full force and effect after such time as a final
decree in divorce may be entered with respect to the parties. The parties agree that the terms
of this agreement shall be incorporated into any Divorce Decree which may be entered with
respect to them and specifically referenced in the Divorce Decree. This Agreement shall not
merge with the divorce decree, but shall continue to have independent contractual significance.
3. DATE OF EXECUTION.
The "date of execution" or "execution date" of this Agreement shall be defined as
the date upon which it is executed by the parties if they have each executed the Agreement on
the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall
be defined as the date of execution by the party last executing this Agreement.
Page 2 of 10
S:\W PDOCS\DOMESTIC\AM1dAVemoslors.mso.wpd
August 26, 1999 ,
4. MUTUAL RELEASES.
Each party absolutely and unconditionally releases the other and the estate of the
other from any and all rights and obligations which either may have for past, present, or future
obligations, arising out of the marital relationship or otherwise, including all rights and
benefits under the Pennsylvania Divorce Code of 1980, and amendments except as described
herein.
Each party absolutely and unconditionally releases the other and his or her heirs,
executors and estate from any claims arising by virtue of the marital relationship of the
parties. The above release shall be effective whether such claims arise by way of widow's or
widower's rights, family exemption, or under the intestate laws, or the right to take against
the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or
all other rights of a surviving spouse to participate in a deceased spouse's estate, whether
arising under the laws of Pennsylvania, any state, Commonwealth, or territory of the United
States, or any other country.
Except for any cause of action for divorce which either party may have or claim
to have, each party gives to the other by the execution of this Agreement an absolute and
unconditional release from all claims whatsoever, in law or in equity which either party now
has against the other.
5. FINANCIAL AND PROCEDURAL DISCLOSURE.
The parties confirm that each has relied on the accuracy of the financial disclosure
of the other as an inducement to the execution of this Agreement. Each party understands that
he/she had the right to obtain from the other party a complete inventory or list of all property
that either or both parties owned at the time of separation or currently and that each party had
the right to have all such property valued by means of appraisals or otherwise. Both parties
understand that they have a right to have a court hold hearings and make decisions on the
Page 3 of 10
S:\W PDOCS\DOMESTIC\MG'AVomaslers.msa.wpd
August 25, 1999
matters covered by this Agreement. Both parties hereby acknowledge that this Agreement is
fair and equitable, and that the terms adequately provide for his or her interests, and that this
Agreement is not a result of fraud, duress or undue influence exercised by either party upon
the other or by any person or persons upon either party.
6. SEPAR.ATIONINON-INTERFERENCE.
WIFE and HUSBAND may and shall, at all times hereafter, live separate and
apart. They shall be free from any interference, direct or indirect, by the other in all respects
as fully as if they were unmarried. Each may, for his or her separate use or benefit, conduct,
carry on and engage in any business, occupation, profession or employment which to him or her
may seem advisable. WIFE and HUSBAND shall not harass, disturb or malign each other or
the respective families of each other.
7. REAL PROPERTY.
WIFE is the owner of real property located at 12209 Fairfield House Drive, Unit
503, Fairfax, Virginia. HUSBAND hereby waives any right, title and interest which he may
have to the home.
HUSBAND and WIFE have executed a separate lease document which governs
the rental rights and obligations of the parties. This lease in no way effects the transfer of
ownership rights herein.
DEBTS.
If a party has acquired debt, the parties agree that each shall assume full and
complete responsibility for his or her own debts.
HUSBAND represents and warrants to WIFE that since the separation he has
not, and in the future he will not, contract or incur any debt or liability for which WIFE or her
estate might be responsible, and lie shall indemnify and save WIFE harmless from any and all
Page 4 of 10
S:\W PDOCS\DOM ESTIC\WAUom aslors.msa.wpd
August 25, 1999
claims or demands made against her by reason of such debts or obligations incurred by him
since the date of said separation, except as otherwise set forth herein.
WIFE represents and warrants to HUSBAND that, since the separation she has
not, and in the future she will not, contract or incur any debt or liability for which HUSBAND
or his estate might be responsible, and she shall indemnify and save HUSBAND harmless from
any and all claims or demands made against him by reason of such debts or obligations
incurred by her since the date of said separation, except as otherwise set forth herein.
9. RETIREMENT BENEFITS
HUSBAND is the owner of one (1) IRA account. WIFE is the owner of two (2) IRA
accounts. HUSBAND hereby waives his right, title and interest in WIFE's IRAs. WIFE hereby
waives her right, title and interest in HUSBAND's IRA. The parties waive any and all other
retirement benefits obtained by the parties. The individual who holds said benefits shall own
the property solely and individually. Each party waives their right to title and interest to the
other party's benefit.
10. BANK ACCOUNTS.
The parties acknowledge that they have divided the marital bank accounts to
their satisfaction. The bank accounts held solely in individual names shall become the sole and
separate property of the party in whose name it is registered. Each party does hereby
specifically waive and release his/her right, title and interest in the other party's respective
accounts.
11. PERSONAL PROPERTY.
The parties hereto mutually agree that they have divided all furniture, household
furnishings and personal property between them in a manner agreeable to both parties. The
f't
Page 5 of 10
S:%W PDOCSIDOMESTICkW AVemaslers,msa,wpd
Augusl25, 1999
parties mutually agree that each party shall from and after the date of this Agreement be the
sole and separate owner of all tangible personal property in his or her possession.
Notwithstanding the above, WIFE shall retain the parties' dog, Coffee.
12. VEHICLES
WIFE is the owner of a 1998 Volkswagen Jetta, which is encumbered by a loan.
HUSBAND hereby waives his right, title and interest in the vehicle. WIFE shall be solely
responsible for the loan associated with the vehicle.
13. BANKRUPTCY OR REORGANIZATION PROCEEDINGS.
In the event that either party becomes a debtor in any bankruptcy or financial
reorganization proceedings of any kind while any obligations remain to be performed by that
party for the benefit or the other party pursuant to the provisions of this Agreement, the debtor
spouse hereby waives, releases and relinquishes any right to claim any exemption to any
property remaining in the debtor as a defense to any claim made pursuant hereto by the
creditor-spouse as set forth herein, including all attorney fees and costs incurred in the
enforcement of this paragraph or any other provision of this Agreement. No obligation created
by this Agreement shall be discharged or dischargeable and each party waives any and all
right to assert that obligation hereunder is discharged or dischargeable.
The parties mutually agree that in the event of bankruptcy or financial
reorganization proceedings by either party in the future, any monies to be paid to the other
party, or to a third party, pursuant to the terms of this Agreement shall constitute support and
maintenance and shall not be discharged in bankruptcy.
14. ALIMONY, SUPPORT, AND ALIMONY PENDENTE LITE
The parties hereby expressly waive, release, discharge and give up any and all
rights or claims which either may now or hereafter have for spousal support, alimony
Page 6 of 10
S:\W PDOCS\DOMESTIC\NW'A\IomaSters.msa.wpd
August 25, 1999
pendente lite, alimony, or maintenance. The parties further release any rights that they may
have to seek modification of the terms of this Agreement in a court of law or equity, with the
understanding that this Agreement constitutes a final determination for all time of either
party's obligations to contribute to the support or maintenance of the other.
15. ATTORNEY FEES. COURT COSTS.
Each party hereby agrees to be solely responsible for his or her own counsel fees,
costs and expenses. Neither shall seek any contribution thereto from the other party except
as otherwise expressly provided herein.
16. ATTORNEYS' FEES FOR ENFORCEMENT.
In the event that either party breaches any provision of this Agreement and the
other party retains counsel to assist in enforcing the terms thereof, the breaching party will
pay all reasonable attorneys' fees, court costs and expenses (including interest and travel costs,
if applicable) which are incurred by the other party in enforcing the Agreement, whether
enforcement is ultimately achieved by litigation or by amicable resolution. It is the specific
Agreement and intent of the parties that a breaching or wrongdoing party shall bear the
obligation of any and all costs, expenses and reasonable counsel fees incurred by the
nonbreaching party in protecting and enforcing his or her rights under this Agreement.
17. WAIVER OF RIGHTS.
Both parties hereby waive the following procedural rights:
(a) The right to obtain an inventory and the appraisement of all
marital and non-marital property;
(b) The right to obtain an income and expense statement of
either party;
(c) The right to have all property identified and appraised;
Page 7 of 10
S:\W PDOCS\DOMESTIC\MGAMemastors.msa.wpd
August 25, 1999 ,
(d) The right to discovery as provided by the Pennsylvania
Rules of Civil Procedure;
(e) The right to have the court make all determinations
regarding marital and non-marital property, equitable
distribution, spousal support, alimony pendente lite,
alimony, counsel fees and costs and expenses.
18. MUTUAL COOPERATION,
WIFE and HUSBAND shall mutually cooperate with each other in order to carry
through the terms of this Agreement, including but not limited to, the signing of documents.
19. VOID CLAUSES.
If any term, condition, clause or provision of this Agreement shall be determined
or declared to be void or invalid in law or otherwise, then only that term, condition, clause or
provision shall be stricken from this Agreement, and in all other respects this Agreement shall
be valid and continue in full force, effect and operation.
20. APPLICABLE LAW.
This Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania.
21. ENTIRE AGREEMENT.
This Agreement contains the entire understanding of the parties, and there are
no representations, warranties, covenants or undertakings other than those expressly set forth
herein.
22. CONTRACT INTERPRETATION.
For purposes of contract interpretation and for the purpose in resolving any
ambiguity herein, the parties agree that this Agreement was prepared jointly by the parties.
Page 8 of 10
S:\W PDOCS\DOMESTIC\14SAVerna9ters,msa.wpd
August 25, 1999
IN WITNESS WHEREOF, the parties hereto have set their hands and seals of
the day first above written.
This Agreement is executed in duplicate, and in counterparts. WIFE and HUSBAND
acknowledge the receipt of a duly executed ropy hereof.
?? Z4 a
ness ISTA ZP113E LEMAS' ERS
Witness
14a.
G IS INFIELD LEMASTERS
S:\W PDOCS\DOMESTIC\MSAVoma.iters.msa.wpd
August 25, 1999
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Qs-- :
SS.
On the °b day of 1999, before me, a Notary Public
in and for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared
CHRISTA ZERBE LEMASTERS, known to me (or satisfactorily proven) to be one of the
parties executing the foregoing instrument, and she acknowledges the foregoing instrument
to be her free act and deed.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and
year first above written.
NoVaNy Public
81-b`iyZLw t'- oy- eowmalA :SS.
eeUNWe
E 1 e Notarial seal Public
State Cooilege Boo, Centre County
My Comrnlsson Expires Sept 5, 2002
On the o97.. day of X66-K , 1999, before me, a Notary Public ire-&n+far
the Ge322m971a+ea1 th f Paaa yl the undersigned officer, personally appeared
GARRISON WINFIELD LEMASTERS, known to me (or satisfactorily proven) to be one of
the parties executing the foregoing instrument, and he acknowledges the foregoing instrument
to be his free act and deed.
IN WITNESS WHEREOF, I have hereunto ,sr?t my hand and notarial seal the day and
year first above written. ? '
ary Public
Commission
JAN1s=
F WALD E CRAWFORD
poMKaWuisr=OFGOLLIM
Vy owm*aw
Page 10 of 10
r• t
.1 c -
n,
C':,; ??;
C .: r,::
l?• ;z)
i _..
L. C7 .'.) a
C.J c: i,J
-._
.,
B
CHRISTA ZERBE LeMASTERS, IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 99-3028
CIVIL ACTION - LAW
GARRISON WINFIELD LeMASTERS,
Defendant IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the court for entry of an
appropriate divorce decree:
1. Ground for divorce: Irretrievable breakdown under § 3301(c) of the Divorce Code.
2. Date and manner of service of complaint: The Complaint was filed on May 19,1999,
and was served on Garrison Winfield LeMasters by certified mail on May 26,1999..
3. (Complete either paragraph (a) or (b):
(a) Date of execution of the affidavit of consent required by § 330 1 (c) of the Divorce
Code: by Plaintiff January 20, 2000; by Defendant January 10, 2000.
(b)(1) MCCtItiOn Of tire affidavit equired by § 3361(d) of tire Divoice
Ea?dc--- ,
4. Related claims pending: None.
5. (Complete either (a) or (b).)
-L_,
(b) Date Plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the
Prothonotary: February 3, 2000.
Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the
Prothonotary: February 3, 2000.
Respectfully Submitted,
REAGER & ADLER, PC
Date: February 3, 2000
Attorney I.D?-ii1n.C6378
CBEL-Eft (ILL)
ZVOO-L LOU Vd '111H dKVO
MRS 13NHVW LEM
MVl 1V SA3NH0J1V
'O'd '1113N'DO3 18 U31av'U3DV31J
c t-:
Ci
t
2
L jui
u.
u
REAGER & ADLER, PC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attorney I.D. No. 66378
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763-1383
Attorneys for Plaintiff
CHRISTA ZERBE LeMASTERS, IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO.
GARRISON WINFIELD LeMASTERS, CIVII ACTION -LAW
Defendant IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following ages, you must take prompt action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be entered against you by the Court. A
judgment may also be entered against you for any other claim or relief requested in these papers by the
Plaintiff. You may lose money or property or other rights important to you, including custody or
visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you
may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary, Room 101, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17043
(717) 249-3166
CHRISTA ZERBE LeMASTERS,
V.
Plaintiff
GARRISON WINFIELD LeMASTERS,
Defendant
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
IN DIVORCE
AVISO PARA DEFENDER Y RECLAIMAR DERECHOS
USTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de las quejas
expuestas en ]as p5ginas siguientes, debar tomar acci6n con prontitud. Se la avisa que is no se defiende,
el caso purde proceder sin usted y decreto de divorcio o anulamiento puede ser emitado en su contra Por
la Corte. Una decisi6n puede tambidn ser emitida en su contra por caulquier otra queja o compensactron
reclamados por el demandante. Usted puede perder dinero, o sus propiedades o otros derechos
importantes para usted.
Cuando la base para el divorcio es indignadades o rompimiento irreparable del matrimonio, usted
puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina
del Prothonotary, en la Cumberland County Court of Common Pleas, Room 101, Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania.
HONORAR OS DE A OGADO U OTRO GASTOSRANTES DE QUE ELF
DECRETO FINAL DE DIVORCO O ANULAMIENTO SEA EMITIDO, USTED
PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS.
SISNOT II E O NO PUEDO PAGAR UN ABOGADO, VAYA O LLAME A LA
OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE SE PUEDE
OBTENER ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17043
(717) 249-3166
REAGER & ADLER, PC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attorney I.D. No. 66378
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763-1383
Attorneys for Plaintiff
CHRISTA ZERBE LeMASTERS,
V.
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9f90,2? etv-U74 -
CIVIL ACTION - LAW
GARRISON WINFIELD LeMASTERS,
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
UNDER § 3301(C) OR (D) OF THE DIVORCE CODE
1. Plaintiff is Christa Zerbe LeMasters, an adult individual, who currently resides at 137 South
Lewisberry Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
2. Defendant is Garrison Winfield LeMasters, an adult individual, who currently resides at 12209
Fairfield House Drive, Unit 503, Fairfax, Virginia, 22033.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6)
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on January 8, 1994 at Cumberland County,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Plaintiff falls within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress
of 1940 and its amendments.
7. Defendant is not in the military or naval service of the United States or its allies within
the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments,
8. Plaintiff avers that there are no children of this marriage.
9. The marriage is irretrievably broken.
10, Plaintiff has been advised that counseling is available and that Defendant may have the right to
request that the court require the parties to participate in counseling. Plaintiff declines counseling.
11. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends
to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit.
12. In the alternative, Plaintiff will file an Affidavit of Consent and provide the appropriate
notices two (2) years from the date of separation.
WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to Section
3301(c) or (d) of the Divorce Code.
COUNTI
j
F-QUITABLF DISTRIBUTION
13. Paragraphs one (1) through twelve (12) of this Complaint are incorporated herein by reference. !
14. Plaintiff and Defendant have acquired property, both real and personal. during their marriage.
2 ,
r
15. The parties have acquired marital debt during the course of their marriage.
16. The parties may be unable to amicably resolve the property issues in this matter.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide all marital
property and debt.
Date: May 17, 1999
Respectfully Submitted,
REAGER & ADLER, PC
`\ )
By:
D RA DENIS N CANTOR, ESQUIRE
Attorney I.brNo. 66378
2331 Market Street
Camp Hill, PA 17011-4642
Telephone No. [7171763-1383
Attorneys for Plaintiff
3
i,
'i
y
VERIFICATION
I, Christa Zerbe LeMasters, verify that the statements made in this Complaint are true and
correct.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unswom falsification to authorities.
Ch rsta Zerbe ast s
Date: e, ?
4
S:\W PDOCS\DOMESTIC\FORMSV\FFIDAVI.SVE
READER & ADLER, PC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attorney I.D. No. 66378
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763-1383
Attorneys for Plaintiff
CHRISTA ZERBE LeMASTERS,
V.
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 99-3028
CIVIL ACTION - LAW
GARRISON WINFIELD LeMASTERS,
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Before me, the undersigned Notary Public, this day, personally appeared Debra Denison Cantor,
Esquire, attorney for the Plaintiff, to me known, who being duly sworn according to law, deposes the
following:
I, Debra Denison Cantor, Esquire, being duly sworn according to law, depose and state that
service of the Complaint in Divorce in the above-captioned matter was served by Certified
Mail, Return Receipt Requested, on Defendant, Garrison LeMasters, 12209 Fairfield House
Drive, Unit 503, Fairfax, Virginia, 12209 on May 26, 1999. The Certified Receipt is
attached hereto as "Exhibit A."
& ADLER, P.C.
By:
Subscribed and sworn {,before me
this.30 dayof??LL?Cn?1 _ '1999.
???Q -?""nipl/L! C{/h
Notary Public NotaneI Lou A. R ard, Nctary PubW-
Camp Hia Eau, CurnDeAarW CpurKy
My Gommrs„gn Expires Oct 1, 2001
Memtwr, PenmWho w &% x hm (4 Motanes
S:\W PDOCS\DOMESTIC\FORMSMFFIDAVI.SVE
aoamonel samcos;
a,.ndwab.
arse atl4me on ifr reverse of this form w that we car
you, •., .
r to the front of the mallpl,M, or on ill beck if apses
,wlptAtpuureC' on tM meilpleeehetow tM' arede numb
On wW e,row to WhM the article was Esiiveredand the de
rested to
3a Lenlas4er
X0q Q
, also with to receive the
following'eerviceffIfor eri extra
feel:
I. O Addressee'a Address
wait heater= or M. S r
4e Article Number to r
4b, Service Type
Ca Reglstered [] Insured
Certified • - DCOD „„m $g
Express Mdl ? Retum Receipt for 5 •,
Marche. wise
7. Dat) of. De very a '-
I
J 6. -.SI stars ( ddres 1 S.Adorec ee' Address (Only if requested `
WA to is paid)
??Jf 8. na ye I ,
PS FOrm ,Dewmbar teo' autapo-,swassna DOMESTIC RETURNRECEIPT
l__?;
E9Et•E9L ILLL)
ZV90-LLOLL Vd'III H dViVO
133H1S13)ItlVW LEM
MVI IV SA3NHO11V
•O•d 'H3lOV V MOM
to
( -5
.'
-
7
:? o U
.
CHRISTA ZERBE LeMASTERS,
Plaintiff
V.
GARRISON WINFIELD LeMASTERS,
Defendant
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3028
CIVIL ACTION - LAW
IN DIVORCE
I. A Complaint in divorce under section 3301(c) of the Divorce Code was filed on May 19,
1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees
or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification
to authorities.
Dated: ) I D& ? D c)
CHRIsTA ZERk}' LeMAS RS
i
Eeet•eeL lull
Z490•L LOLL Vd'11IH dWV3
133H1S13HHVW LEEZ
MV1 1V SA3NHOLLV
'O'd 'I113N000 V 8310V'H30V38
U ` C7
r,
7
'L) cn,
CM (J
CHRISTA ZERBE LeMASTERS,
Plaintiff
V.
GARRISON WINFIELD LeMASTERS,
Defendant
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3028
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER SECTION 33..01fs1 OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees
or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court and
that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification
to authorities.
Dated: I I ') U I GO
eaeL-69L (M)
Z63PL LOLL Vd'ITH dWV0
133HIS 13AHVW LCCZ
MVl 1V SA3NH011V
'1113N000 R N310V'N30V3H
?r u)
O (?
I
,
CHRISTA ZERBE LeMASTERS,
Plaintiff
V.
GARRISON WINFIELD LeMASTERS,
Defendant
: IN THE OF COMMN PLEAS'
:CUM ERCLO AND COUNTY, ENNSYLVANIA
NO. 99-3028
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF coNCFNT
1. A Complaint in divorce under section 3301(c) of the Divorce Code was filed on May 19,
1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees
or expenses if I do not claim them before a divorce is granted.
11 I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification
to authorities.
i
Dated: V cypv 0V
f
*SO I b Le ASTERS
lU ?-
C(
? G L.
v
,
'
f l' ?.(
y
r:'?1 1
1.; 1 I l
' L I ? '
?"? i.
I 11.1J
l?
?
? 1? -?
`
? C.1 U
CHRISTA ZERBE LeMASTERS, : IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 99-3028
CIVIL ACTION - LAW
GARRISON WINFIELD LeMASTERS,
Defendant IN DIVORCE
WAIVER OF NOTICE. OF INTENTION TO REQUEST
ENTRY OF A DIVOR _ . DF. FF,
IINDFR SECTION 3301(C) OF THR DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division ofproperty, lawyer's fees
or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court and
that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification
to authorities.
Dated: P5,40 ZWO
ISON WI FI LD LeMASTERS
n c L
(?)
1
2-
u
L:.t .?iI CL ..
co ??
CHRISTA ZERBE LeMASTERS, : IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 99-3028
CIVIL ACTION - LAW
GARRISON WINFIELD LeMASTERS,
Defendant IN DIVORCE
PRAECIPE
i
i
TO THE PROTHONOTARY:
The Social Security number of the Plaintiff, Christa Zerbe LeMasters, is 180-54-6125.
i
The Social Security number of the Defendant, Garrison Winfield LeMasters, is 189-62-5242.
Respectfully Submitted,
REAGER & ADLER, PC
r
Date: February 3, 2000
Attorney I.D o 6378
2331 Market Street
Camp Hill, PA 17011-4642
Telephone No. [717] 763-1383
Attorneys for Plaintiff
EO£L•£OL ILLL)
ZOWUOLL WITH dVYVD
ANA A NUM LE£L
MVl1V SA3NHOLLV.
'O'd'LLANOOO R U310V'tl30V3H
Ly Lf)
F= -
i -
``:.'ice.,
1. .. . r
Lt.:
L1
cD Cj
CHRISTA ZERBE LCMASTERS,
Plaintiff
V.
GARRISON WINFIELD LCMASTERS,
Defendant
IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO.: 99-3028
CIVIL ACTION - LAW
IN DIVORCE
NOTICE OF ELECTION TO RETAKE MAIDEN NAME
Notice is hereby given that the Plaintiff in the above matter, having been granted a Final
Decree in divorce from the bonds of matrimony on the 16th day of February, 2000, hereby elects
to retake and hereafter use her previous name of CHRISTA SUZANNE ZERBE.
CHRISTA ZE E LEM ERS
TO BE KNOWN AS:
_?.h
CHRISTA SUZ ZERBE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ?,? yJ tr'L SS Vro -" -(a,
On the.--Ly- day of _ q v 2000, _.___ , 000, before me a Notary Public personally ?.
appeared CHRISTA ZERBE LEMASTERS t/b/k/a CHRISTA SUZANNE ZERBE, known to
me to be the person whose name is subscribed to the within document and acknowledged that she
executed the foregoing for the purpose therein contained,
IN WITNESS WHEREOF, I have hereunto set in hand and official seal
ary P lic
=E.SHAY. AL
RY PUBLIC
e County
)usr75, 2001
1
?? o y
' r) `i
c). i
.T
[,ll.
1.11 C 1
?_
(,i„_
^
? O
(J G ? ? ?
ll _
n